PRIVACY AND COOKIES POLICY
WHO WE ARE. We are pmtvinhos, and we process your personal data as joint controllers. This means that we are jointly responsible for the way we treat and protect your data.
WHAT WE USE YOUR DATA FOR. We will use your data (collected online or in person), among other purposes, to manage your registration as a user, to manage your purchases of products or services, to answer your questions and, if you wish, to send you personalized communications.
WHY WE USE YOUR DATA. We have the legitimacy to process your data for several reasons. The main reason is related to our need to process your data in order to execute the contract that you agree to enter into with us when you register and when you make a purchase or enjoy any of our services or features. We also use your data for other reasons, for example, to answer your questions or to send you newsletters, which you have requested to be sent.
WITH WHOM WE SHARE YOUR DATA. We share your data with service providers that provide assistance or support, whether these companies are part of the Inditex Group or third party suppliers, inside and outside the European Union.
YOUR RIGHTS. You have the right to access, rectify or delete your personal data. In certain cases, other rights are recognized, such as, for example, the right to object to the use of your data or the transfer of your data, as explained in more detail below.
BEFORE YOU BEGIN… • In this Privacy and Cookies Policy you will find all relevant information regarding your use of the personal data of our users and customers, regardless of the channel or the means (online or in person) of pmtvinhos that you use to interact with us.
• We are transparent about the use we make of your personal data, so that you understand the implications of how we use your data and the rights that are granted to you regarding your data:
you may also find additional information regarding the use we make of your data as you interact with us.
o When referring to our Platform, we generally refer to any of the channels or media, digital or in person, that you may have used to interact with us.
The main ones are:
▪ Our Site, www.pmtvinhos.pt
▪ Our App from www.pmtvinhos.pt, that is, including both the mobile application you installed on your mobile device and others that we can use in our stores.
▪ In person, in any of our pmtvinhos.
WHO IS RESPONSIBLE FOR THE TREATMENT OF YOUR DATA?
The controllers of your data are:
Pmtvinhos, a company currently operating in Portugal in the sale of products under the XXXXX brand (“XXXX PORTUGAL”). o Postal address: Rua Dr. Eduardo Santos Silva, 261 - Fração C2, 4200-283 Porto Portugal. o Data Protection Officer e-mail address: firstname.lastname@example.org
In other words, pmtvinhos (together "We", or "Joint Controllers"), are Joint Controllers of the data. This means that we have regulated and are jointly responsible for the processing and protection of your personal data.
WHY WE TREAT YOUR PERSONAL DATA Depending on the purpose for which we process your data at all times, as explained above, we need to process some data which, in general, will be, depending on each case, the following:
▪ Your identification data (for example, your name, surname, language and country from which you interact with us, contact details, etc.);
▪ economic and transaction information (for example, your payment or card details, information regarding your purchases, orders, returns, etc.);
▪ connection, geolocation and / or navigation data (if you interact with us via your mobile phone, for example):
▪ commercial information (for example, if you have subscribed to our newsletter),
▪ information about your tastes and preferences. Remember that when we ask you to fill in your personal data to give you access to any functionality or service on the Platform, we will mark certain fields as mandatory, since these are the information we need to be able to provide you with the service or give you access to the functionality in question. Please note that if you decide not to provide the said data, you may not be able to complete your user registration or you may not be able to enjoy these services or features. In specific cases, a third party may provide us with information about you using a feature or service on the Platform, for example, by sending you a gift card or by sending an order to your address. In such cases, we only process data whenever relevant to this feature or service, as indicated in this Privacy and Cookies Policy. Depending on how you interact with our Platform, that is, depending on the services, products or features you want to enjoy, we will treat your personal data for the following purposes:
Development, fulfillment and execution of the contract for the purchase or provision of services The processing of your data is necessary for the conclusion of the contract for the purchase or provision of services with you. Certain processing of data related to the purchase process is activated only because you request or authorize it, such as the storage of payment data (card) for future purchases, or the processing of data necessary to read receipts through the section App Wallet, or to provide you with the Back Soon / Back Now features (where such features are available). In these cases, the way we process your data is based on your own consent. We consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud, or fraudulent use of the Platform, for example, when making a purchase or return. We understand that the processing of this data is positive for all parties involved: For you, as it allows us to create measures to protect you against fraud attempts perpetrated by third parties; for us, as it allows us to avoid unauthorized uses of the Platform; for all our customers and society, as it also protects their interest by ensuring that fraudulent activities are discouraged and detected when they occur.
Customer Support We believe that we have a legitimate interest in responding to requests or questions that you ask us through the various existing contact channels. We understand that the treatment of these data is also beneficial for you, as it allows us to provide you with adequate assistance and answer the questions asked. When you contact us, in particular, for the management of incidents related to your order or the item / service purchased through the Platform, the processing of your data is necessary for the conclusion of the purchase contract. When your request is related to the exercise of the rights to which we inform you below, or to complaints related to our products or services, we are legally authorized to process your data for the purpose of complying with our legal obligations.
. Marketing We are legally authorized to process your data for marketing purposes as you give us your consent, for example, when you accept to receive personalized information through different channels, when you accept to receive push notifications on your mobile phone or configure the settings of your device mobile to allow personalized advertising, or when you accept the terms and conditions to participate in a promotional action or to publish your photos on the Platform or on our social media channels. In order to provide you with personalized services, or to show you personalized information, whether on our Platform or on third parties, and to engage in data enrichment, we consider that we have a legitimate interest in conducting a profile check with the information we have about you. you (such as, for example, browsing history, preferences or purchases) and the personal data you have provided to us, for example, age range or language, as we understand that processing this data is also beneficial for you once which allows you to improve your user experience and access information according to your preferences.
Analysis of functionality and quality We consider that we have a legitimate interest in analyzing the functionality of the Platform and the degree of user satisfaction, as we believe that the treatment of this data is also beneficial for you, since the purpose is to improve the user experience. and offer a more quality service.
DURING HOW LONG WILL WE KEEP YOUR DATA?
The period of retention of your data will depend on the purposes for which we treat it, as explained below:
Purpose Shelf life
Managing your registration as a Platform user We will process your data for as long as you remain a registered user (that is, until you decide to cancel your subscription).
Development, fulfillment and execution of the contract for the purchase or provision of services We will process your data for the time necessary to manage the purchase of the products or services you have purchased, including possible returns, complaints or complaints associated with the purchase of the product or service in question. Sometimes, we will only process the data until the moment you decide, such as the payment data (card) that you asked us to store for future purchases (whenever such a feature is available).
. Customer Support We will process your data for as long as necessary to fulfill your request or request.
For marketing purposes. This purpose includes the processing of your data, mainly to: ▪ Personalize the services we offer you and allow us to provide you with recommendations based on your interactions with pmtvinhos on the Platform and an analysis of your user profile (for example, based on your purchase and browsing history). ▪ If and when you subscribe to our Newsletter, we will treat your personal data to manage your subscription, including to send personalized information about our products or services through various means (such as by email or SMS). We can also make this information available to you through push notifications. if you have enabled them on your mobile device. ▪ Therefore, bear in mind that the said data processing involves the analysis of your user or customer profile to establish your preferences and, therefore, which products and services are best suited to your style when we send you information . For example, based on your purchase and browsing history (that is, depending on the items you clicked on), we will suggest items that we think may interest you and, if you are a registered user, we will provide you with the "cart recovery" functionality.
Perform promotional actions (for example, for the organization of contests or to send the list of items saved to the email address you have indicated to us). By participating in any promotional action, you authorize us to process the data you have made available to us depending on the promotional action and to communicate it through various means such as social networks or on the Platform itself. In each promotional action you participate will have available the terms and conditions through which we will give you more detailed information about the processing of your personal data. ▪ broadcast on the Platform, or through our channels on social networks, photographs or images that you have shared in a public way, whenever you give us your express consent to this purpose.
Analysis of functionality and quality to improve our services If you access our Platform, we inform you that we will process your browsing data for analytical and statistical purposes, that is, to understand how users interact with our Platform and with the actions we implement on other web pages and apps, so that we can improve our services. In addition, we will occasionally conduct surveys and quality actions to know the degree of satisfaction of our customers and users and to detect the areas in which we can improve.
HOW ARE WE LEGALLY AUTHORIZED TO PROCESS YOUR DATA? The legal grounds that allow us to process your personal data also depend on the purpose for which we process it, as explained in the following table: Purpose Legitimacy Manage your registration as a user of the Platform The processing of your data is necessary in accordance with the terms governing the use of the Platform. In other words, in order to register as a user on the Platform, we need to process your personal data, otherwise we could not manage your registration. Development, performance and execution of the contract for the purchase or provision of services The processing of your data is necessary for the conclusion of the contract of purchase or provision of services with you. Certain processing of data related to the purchase process is activated only because it requests or authorizes it, such as the case of storing payment data (card) for future purchases, or the processing of data necessary to read receipts through the Wallet section of the App, or to provide you with the features I will be back soon / I will return now (where such features are available). In these cases, our processing of your data is based on your own consent. We consider that we have a legitimate interest to carry out the necessary checks to detect and prevent possible fraud, or fraudulent uses of the Platform, for example when making a purchase or return. We understand that the processing of this data is positive for all parties involved: For you, as it allows us to create measures to protect you against fraud attempts perpetrated by third parties; to us, as it allows us to avoid unauthorized uses of the Platform; for all our customers and society as it also protects their interest by ensuring that fraudulent activities are discouraged and found when they occur.
Customer Support We believe that we have a legitimate interest in responding to requests or questions you ask us through the various existing contact channels. We believe that the processing of this data is also beneficial to you, as it allows us to provide you with adequate assistance and answer the questions asked. When you contact us, in particular, for the management of incidents related to your order or the article/service purchased through the Platform, the processing of your data is necessary for the conclusion of the purchase contract. Where your request relates to the exercise of the rights we provide you with below, or to complaints relating to our products or services, we are legally authorized to process your data for the purposes of compliance with our legal obligations. . Marketing We are legally authorized to process your data for marketing purposes as you give us your consent, for example, when you agree to receive personalized information through various channels, when you agree to receive push notifications on your mobile phone or configure your mobile device settings to enable personalised advertising, or when you accept the terms and conditions to participate in a promotional action or to post your photos on the Platform or on our social media channels. To provide you with personalized services, or to show you personalized information, whether on our Platform, or third party data, and also to engage in data enrichment, we consider that we have a legitimate interest in conducting a profile check with the information we hold about you (such as browsing history, preferences or purchases) and the personal data you have provided to us, such as age or language, as we understand that the processing of this data is also beneficial to you as it allows you to improve your user experience and access the information according to your preferences.
Functionality and quality analysis We consider that we have a legitimate interest in analyzing the functionality of the Platform and the degree of user satisfaction, as we understand that the processing of this data is also beneficial to you, since the purpose is to improve the user experience and offer a more quality service. HOW LONG WILL WE KEEP YOUR DATA? The retention period of your data will depend on the purposes for which we treat it, as explained below: Purpose Conservation period Manage your registration as a user of the Platform We will process your data for as long as you maintain your registered user status (i.e. until you decide to cancel your subscription). Development, performance and execution of the contract for the purchase or provision of services We will process your data for as long as necessary to manage the purchase of the products or services you have purchased, including possible returns, complaints or complaints associated with the purchase of the product or service in question. Sometimes we will only process the data until the time you decide, as is the case with the payment data (card) you asked us to store for future purchases (whenever such a feature is available). . Customer Support We will process your data for as long as necessary to fulfill your request or request. Marketing We will process your data until you cancel your newsletter subscription. This will show you personalized advertising until you change your phone or browser settings, such as if your permission to do so is revoked. If you participate in promotional actions, we will retain your data for a period of six (6) months from the end of the action.
Functionality and quality analysis We will treat your data sporadically for as long as we perform a particular quality action or survey or even anonymize your browsing data. Regardless of whether we process your data for as long as is strictly necessary to fulfill the corresponding purpose, we will subsequently retain it properly stored and protected for as long as liability arising from the processing may arise, in accordance with the legislation in force at any time. When each of the possible actions prescribes, we will delete the personal data. DO WE SHARE YOUR DATA WITH THIRD PARTIES? In order to fulfill the purposes indicated in this Privacy and Cookies Policy, it is necessary to give access to your personal data to inditex Group entities and to third parties who provide us with support in the services we offer you, i.e.: ▪ financial institutions, ▪ Anti-fraud prevention and detection entities, ▪ providers of analytical and technological services, ▪ Service providers and service partners for logistics, transport and delivery and/or partner establishments, ▪ service providers related to customer support, ▪ Service providers and employees related to marketing and advertising, such as social media pages, advertising agencies or advertising partners. For reasons of service efficiency, some of the providers mentioned are located in territories located outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union, i.e. the United States. In such cases, we inform you that we transfer your data with adequate safeguards and always maintain the security of your data: ▪ Some providers are certified under the Privacy Shield, a certification you can refer to at the following link: https://www.privacyshield.gov/welcome ▪ With other providers, we have entered into standard contractual clauses approved by the Commission and the content of which you can see at the following link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/modelcontracts-transfer-personal-data-third-countries_en
WHAT ARE YOUR RIGHTS WHEN YOU MAKE YOUR DATA AVAILABLE TO US We undertake to respect the confidentiality of your personal data and to guarantee you the exercise of your rights. With this, we joint controllers agree that you can exercise your rights at no cost by sending us an email to email@example.com, indicating to us only the reason for your request and the right you wish to exercise. In case we deem it necessary for us to identify you, we may request a copy of an ID. In particular, regardless of the purpose or legal basis under which we process your data, you are entitled to: • Request access to your personal data that we have. Please note that if you are a registered user on the Platform, you can also consult this information in the section corresponding to your online account. • Request that we rectify the data we have. Please note that if you are a registered user of the Platform you can also access the section corresponding to your personal account data to change or update your personal data. In any case, please note that by actively providing us with your personal data by any means, you warrant that they are authentic and accurate and undertake to notify us of any change or change thereof. Any loss or damage caused to the Platform or to the person responsible for the Platform or any third party arising from a communication of incorrect, inaccurate or incomplete information on the registration forms shall be the sole responsibility of the user. Remember that, as a general rule, you should only provide us with your own personal data, not those of third parties, unless otherwise permitted in this Privacy and Cookies Policy. • Request that we erase your data to the extent that it is no longer necessary for the purpose for which we need to continue to process it, as explained above, or when we are no longer legally authorized to treat it. • Request that we cancel or limit the processing of your personal data, which means that in certain cases you may ask us to temporarily suspend the processing of the data or its retention beyond the time required. If you have given us your consent to process your data for any purpose, you also have the right to withdraw it at any time. Some of the ways in which you can revoke your consent are detailed in section 2, in which we explain what are the purposes of processing your data. For example, if you don't want us to send information to third parties to show you advertising, you can change your preferences on your phone by restarting your advertising ID or disabling personalised advertising on your device.
If you have our App installed on an iOS device, you can change your preferences in Settings/Privacy/Advertising. If your device is Android, go to Settings/Google/Advertising. If you are visiting the website, you can change the cookie settings in your browser. When we obtain legitimacy to process your data through your consent or for the purposes of the contract, as explained in section 3, you will also be entitled to request the portability of your personal data. This means that you will be entitled to receive the personal data that you have made available to us in a structured, commonly used and automatic reading way, so that you can transmit it directly to another entity without any impediment on our part. Furthermore, since the processing of your data is based on your legitimate interest, you also have the right to challenge their processing. Finally, we inform you that you have the right to lodge a complaint with the data protection supervisory authority, in particular the ▪ Spanish Data Protection Agency https://www.agpd.es/portalwebAGPD/index-ides-idphp.php ▪ The authority of the country in which the retail company is located: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm WHAT HAPPENS WHEN YOU PROVIDE US WITH THIRD PARTY DATA OR IF A Third Party HAS PROVIDED US WITH YOUR DATA?
What types of Cookies are there? This section provides an overview of the types of Cookies that can be used in an online environment. Depending on their owner, cookies can be classified as: A. Own cookies: These are those that are sent to the user's computer or device from a device or domain managed by the publisher itself and from which the platform or service requested by the user is offered. B. Third-party cookies: These are those that are sent to the user's computer or device from a device or domain that is not managed by the publisher, but by another entity that treats the data obtained through cookies. Depending on their purpose, Cookies can be classified as: A. Strictly necessary (technical) cookies: These are those that allow the user to navigate through a website, platform or application and the use of the different options or services that exist in them, such as controlling traffic, identifying data or the session, accessing sections or content sums of restricted access, remembering the integral elements of an order, making the process of purchasing an order , manage payments, control fraud related to service security, use security features while browsing, request registration or participation in an event, store content for the dissemination of videos or sound, enable dynamic content (e.g. text or image upload animation), or share content over social networks. Technical cookies, being strictly necessary, are downloaded, by default, when they allow you to show the platform or provide the service requested by the user. B. Functionality or personalization cookies: These are those that allow you to remember information so that the user can access the service or platform with certain characteristics that can differentiate your experience from that of other users, such as the language, the number of results to show when the user does a search, the appearance or content of the service depending on the type of browser used by the user or the region from which you access the service , etc. Non-acceptance of these Cookies may lead to slow website performance or poorly adapted recommendations.
Who uses the information stored in cookies?
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